The tax on non-operational assets, presented in the PLF 2026, has a specific objective, to make it more expensive to sleep money in asset holding companies. The idea is to discourage hoarding while sparing working capital. Mounir Mahjoubi, Partner Tech M&A at Matin Partners and former Secretary of State for Digital, defends the spirit of the reform but calls for fine calibration so as not to penalize investment in innovation.
The heart of the device
The text creates an annual tax of 2% on the net value of non-operating assets held by certain companies controlled by individuals. Central trigger, more than 50% passive income such as dividends, interest, rent, portfolio capital gains, asset threshold beyond which the tax applies. The reference document also details a franchise and reductions on recently raised capital and sale proceeds awaiting reuse. The stated objective is to tax the inactive use of capital rather than wealth as such.
The basis covers cash, investments and non-operating real estate; sustainable equity securities, certain fund shares, as well as securities of active European SMEs are excluded. The exclusion rule protects entrepreneurial holding companies that run and charge for real activity.
Blind spots
Temporality: the 24-month window for reusing sale proceeds is considered too short, with the identified risk of taxing the break between two adventures which can discourage post-sale founders and business angels who reinvest slowly and cautiously. Typical case. A founder who sells for €10 million then leaves the cash in the holding company would be exposed to 2% per year from the third year, despite an IS already paid on financial income.
Perceived fairness: the listed strategic holdings of very large family holding companies are excluded from the basis when a diversified portfolio of shares is treated like cash. The paradox fuels the idea of a double standard to the detriment of the “recent rich”.
Complexity: the active vs. passive income boundary at 50% creates a permanent need for proof. The risk of litigation increases if the administration does not harmonize the interpretation.
The proposed fixes
Three structuring adjustments emerge in Mahjoubi’s note.
- Extend the re-employment period from 24 to 36 or 48 months. Recognize the time for risk, trial and sometimes failure before restarting.
- Create an active investment status at risk over three years for holding companies which reinvest at least 10% of their assets in a new activity. Expected effect. Temporary protection against the tax even if the project fails or does not yet generate turnover.
- Introduce a symbolic and proportionate contribution from mega-holdings. Reintegrate 15% of the value of ultra-liquid listed holdings into the base beyond a very high asset threshold. Objective. Reduce the perceived bias against post-cession entrepreneurs without switching to a “full Zucman” version.
A ridge line
The desired balance is to discourage rents without breaking the dynamic of reinvestment, avoid the window tax which satisfies public opinion but weakens the ecosystem, and direct taxation towards the productive use of capital rather than uniform sanctions. The final version will say whether the tax becomes an effective allocation tool or a political signal without impact on the real economy.
References
Complete analysis. “PLF 2026 Analysis – Taxe Holdings. Zucman or not enough?” by Mounir Mahjoubi. Version of October 14, 2025. The technical elements on the base, exclusions, reductions and adjustment proposals come from this document.
